Delete this policy and replace with a new policy based on viability testing of housing market areas also taking account of the above comments.

This is the first time that the HBF has seen an affordable housing policy like this, in that it proposes a percentage requirement based on the size of the site rather than the viability of the area. Such an approach is not supported by the Welsh Government Development Plan Manual 3. Further such an approach takes no account of market areas which vary greatly in this area due to the geographical size and differences between the unban and rural areas, as identified by Appendix A of the viability document. These areas were used by the LHMA but have then not been used by the policy to consider viability by area. There is no explanation in the plan or the Viability evidence document as to why this different approach has been used.

CARMARTHENSHIRE HOUSE PRICE DATABASE SUMMARY as at November 2022 : APPENDIX B indicates average prices range across the borough from £164K - £284K which highlights the impact location will have on viability. Further the same table indicates that the increase in prices since 2019 has varied greatly between 13.1% and 56.9% again highlighting the difference in market areas.

No 'key sites' viability assessment has ben carried out, other recent RLP's have shown that these sites need to be considered differently to the high level viability assessment.

The wording of the policy states 'The affordable housing target percentage noted is a target to be used as a starting point for affordable housing negotiation'. This is unacceptable and contradicts its self if its a target it can't also be the starting point.

As is the normal practice there is no mention of viability within the policy and the need to consider whether it is viable for the scheme to deliver affordable housing along with many other potential S106 cost.

The idea of using the aggregate number of adjacent sites is not appropriate if the sites are being developed by different developers. Its is presumed that this wording is trying to avoid sites being subdivided to reduce affordable housing requirements, if this is the case then this is what it should say.

The requirement for perpetuity should not be contained within the policy wording and the acceptability of it should be checked with local RSL's.